Home Health & Hospice Week

Beware increased documentation requirements in the future.

Home care providers may be interested in one provision of Medicare’s newly released physician fee schedule payment rule for 2022.

Reminder: “Effective June 8, 2021, we announced a new add-on payment with a national rate of $35.50 when a COVID-19 vaccine is administered in the beneficiary’s home,” the Centers for Medicare & Medicaid Services notes in the rule issued July 13. “Providers and suppliers administering a COVID-19 vaccine in the home will be paid a national average payment $75.50 dollars per dose ($40 for COVID-19 vaccine administration and $35.50 for the additional payment for administration in the home, and both payments are geographically adjusted),” CMS summarizes in the rule scheduled for publication in the July 23 Federal Register.

Clarification: “The COVID-19 vaccine administration service must be furnished inside an individual’s home,” CMS explains in the rule. “An individual unit in a multi-dwelling building is considered a home. For example, an individual apartment in an apartment complex or an individual bedroom inside an assisted living facility or group home is considered a home.”

However, “communal spaces of, or related to, congregate living arrangements (such as a communal area of an apartment or condominium complex, assisted living facility, group home) are not considered a home for purposes of this add-on payment because multiple people could be vaccinated and monitored either simultaneously or in tandem in such communal spaces,” CMS details.

Another clarification: “In situations where more than one Medicare beneficiary lives in the same individual home, the additional payment for COVID-19 vaccine administration in the home is limited to one time in that home on that day, while any additional COVID-19 vaccine administration services for other individuals in that same home would be paid at the generally applicable rate of approximately $40 without the additional in-home add-on payment amount,” CMS makes clear.

LUPA Rate Informs Vaccination Add-On

By the way: “We used the home health low utilization payment adjustment add-on factor for skilled nursing as a proxy for the increased resource costs, above those reflected in the base payment rate for COVID-19 vaccine administration, involved in arranging and furnishing COVID-19 vaccine administration services in the home,” CMS explains. Medicare applied the 1.8451 SN factor to the base rate for COVID-19 vaccine administration of $40 per dose.

The vaccination add-on in the home is “preliminary” and CMS solicits comments on a number of specific areas, including the definition of “home” for payment purposes, data on additional in-home vaccination costs, possible new documentation requirements, and more. Comments are due Sept. 13.

Note: See the 1,747-page rule and instructions on how to submit comments at https://public-inspection.federalregister.gov/2021-14973.pdf.